Does an SEC registered firm have to register with a state?
An SEC registered investment advisory firm does not have to register with state securities regulators. However, an SEC registered firm is required to notice file with each state where it maintains a place of business or if the firm has more than 5 investment advisory clients. (It should be noted that certain states, such as Texas, do not recognize this de minimus exemption and require notification upon the first client.) In most states, an SEC registered firm can notice file with a state securities regulator by electronically submitting the Form ADV Part I via the IARD system and paying the state its notice filing fee.
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